30 Mar Task Force Provides Input on CMS Proposed Rulemaking on Medicare Shared Savings
The Task Force supports many of the Proposed Rule’s policies, several of which we have advocated for in past comment letters. In this letter we provide input, raise questions, and offer suggestions to CMS on the proposed changes, organized into the Proposed Rule’s three main sections: (1) Revised Benchmarking; (2) Facilitating the Transition to Risk; and, (3) Administrative Finality of Financial Calculations.
1. Revised Benchmarking Policy. The Task Force fully supports CMS’ decision to integrate regional factors into the benchmark rebasing methodology, as it will help to create greater sustainability for the MSSP and its ACOs.
2. Facilitating the Transition to Risk. We urge CMS to allow ACOs to move up the risk tracks between performance years without waiting for a new agreement period.
3. Administrative Finality. We urge CMS to shorten the reopening period to provide ACOs with more financial certainty and suggest a two-year window instead. The HCTTF askes that CMS outline specific processes for circumstances when an ACO seeks payments reopening and is prepared to present evidence that an error has been made. The Task Force also urges CMS to establish policy for a materiality threshold on an individual ACO level and consider a materiality threshold of 2 percent.
Read the letter for the full response to the Proposed Rule from the Task Force.
Letter submitted on March 28, 2016